I’ve seen a couple of articles on the North Dakota Supreme Court case  of Dokter v. Burleigh County Board of Commissioners, discussed here, that suggest this case is causing quite the stir in the Peace Garden State (yes, I looked that up).  As in some other Upper Midwest states, townships have authority to adopt zoning.  Also as in some of these other states, the ability for townships to do so is subject to legislative rules that define the limits of that authority vis-a-vis county authority to do the same.  Prior to the 2015 state legislative session a township that unilaterally relinquished zoning authority to the county could not reclaim that authority.  Under a bill passed this year townships can now do so by mutual agreement with the county commission.

The Dokter case is apparently causing townships to consider this option.  A good article on this, and the “arbitrary and capricious” standard of review for zoning decisions adopted by most state courts (actually all state courts that I am familiar with) can be found here.